0596-NEW--NTFP Supporting Statement A

The 2017 Supporting Statement for OMB 0596-NEW

Generic ICR for Surveys, Interviews, and Focus Groups on Non-timber Forest Products

1. Justification

1. Explain the circumstances that make the col­lection of information necessary. Iden­tify any legal or administrative require­ments that necessitate the collection. Attach a copy of the appropriate section of each statute and regulation mandating or authorizing the col­lection of information.

The purpose of this Generic Information Collection Request (ICR) is to request OMB approval to collect information that will help the Forest Service sustainably manage and provide guidance to others about managing Non-Timber Forest Products (also known as NTFPs). Surveys, interviews, and focus groups administered under this Generic Clearance will be designed to collect information from individuals and groups who forage for Non-Timber Forest Products and from natural resource professionals who manage land where Non-Timber Forest Products foraging takes place. This ICR contains the entirety of questions that this research team may deploy to successfully answer our research questions, and the methods selected and questions posed will be carefully determined based on individual, group, and site factors, as explained in this document.

The USDA Forest Service needs an accurate understanding of the role of foraging of Non-Timber Forest Products from National Forests and other lands. This is critical to supporting our mission of both managing National Forests and collaborating with others to develop useful guidelines for management of the forests of the Nation (not only the National Forests). This effort requires a sound scientific basis and the engagement of Agency social science researchers.

The data collection efforts initiated under this clearance will be similar in terms of the populations being surveyed (foragers or managers of foraged materials), the types of questions being asked, and the research methods used. The USDA Forest Service Research & Development Social Science Program will conduct the necessary quality control (described below and in Part B) to assure each survey instrument conforms with the guidelines of this Generic Clearance and will submit each information collection request to OMB for expedited review. Each collection will clearly fit within the overall plan and scope of this Generic Clearance and be well defined in terms of its sample or respondent pool and research methods. Standardization of methods and content across the country is important to providing reliable and consistent information to land managers and foragers over time.

The information collected under this ICR will greatly assist delivery of high quality customer service. Because of the wide range of people who forage, and the percentage that use foraged products in critical cultural capacities and/or as important contributions to their food supply, understanding foraging of Non-Timber Forest Products is also important to ensuring environmental justice.

Non-Timber Forest Products are plants, mushrooms, and plant- or tree-derived goods like nuts, boughs, sap, and leaves that are harvested for use as food, medicine, and other purposes. Previous research suggests that approximately 20% of the U.S. population collects non-timber forest products for social, cultural, and/or economic reasons. Some non-timber forest products gathering is formal (planned, systematic) while much of it is informal (unplanned, opportunistic, and/or incidental to other outdoor recreation activities). For some people, harvested wild plants and mushrooms make up a substantial or nutritionally important part of their diet. In other cases, non-timber forest products are locally or regionally important products for businesses.

Many opportunities exist to design and manage forests and other natural areas to enhance the supply of non-timber forest products. This increases the benefits they provide to society, and helps maintain populations of, or adapt to loss of, important non-timber forest products in the face of changes like invasive species and climate impacts. Potential benefits include improved public health outcomes from outdoor activity including decreased obesity, diabetes, stress, and depression. Harvesting and consuming non-timber forest products also may help reduce the risk of malnutrition for individuals living in areas with limited access to fresh, affordable food. Designing and managing for non-timber forest products may have particular value in ensuring environmental justice, as harvesting wild plants and mushrooms appears to be especially important for recent immigrants, American Indians, and Alaska Natives. However, managing forests and other natural areas to provide non-timber forest products in a sustainable way requires detailed, scientifically-based information that is not currently available. For example, it is important to avoid overharvesting any species and to minimize people’s exposure to soil- and plant-based contaminants.

Many laws and policies specifically direct the USDA Forest Service (Forest Service) to consider and manage for Non-Timber Forest Products for the benefit of the American public and to meet trust responsibilities to American Indians and Alaskan Natives on federal and tribal lands. The Multiple-Use Sustained-Yield Act of 1960 requires the Forest Service to manage National Forests “under principles of multiple use and to produce a sustained yield of products and services.” The Forest and Rangeland Renewable Resources Planning Act (RPA) of 1974 requires the Secretary of Agriculture to “maintain a comprehensive inventory of renewable resources and evaluate opportunities to improve their yield of goods and services.” The 2012 Planning Rule specifically requires “consideration of habitat conditions for wildlife, fish, and plants commonly enjoyed and used by the public for hunting, fishing, trapping, gathering, observing, and subsistence” on national forests [italics added]. The Forest Service’s 2010 National Report on Sustainable Forests affirms the agency’s “all-lands” approach to managing the nation’s natural resources, including forests that are not part of the National Forest system; gathering of non-timber forest products is addressed many times in this report. The United States is a signatory to the Montreal Process and is required to report every 5 years on a range of criteria and indicators for sustainable use of temperate and boreal forests. Several of the indicators address Non-Timber Forest Products, including one on subsistence uses of U.S. forests, but the only systematic data currently available on subsistence practices in the United States are for Alaska.

This lack of data also limits our capacity to assess how we are meeting obligations related to U.S. policy and law including treaties with American Indian tribes, the Federal Trust responsibility to tribes, and the Native American Religious Freedom Act. The Federal Government has trust responsibility to federally recognized American Indians regarding health, welfare, and education. Non-Timber Forest Products make up a significant amount of the natural resources that tribes depend on for traditional cultural uses related to health, economic and food security, and native customs and practices. Much of the historical and ethnographic information about the uses of Non-Timber Forest Products by American Indians and Alaskan Natives may not reflect contemporary uses and issues. Gaining new information can help us understand how uses of Non-Timber Forest Products have changed over time in response to management, socio-cultural circumstances, the economic conditions of tribes, and environmental forces of change.

Taking all of this into account, it is clear that Forest Service and other public and private land managers need general and place-specific information about non-timber forest products and non-timber forest product harvesting practices. This information is not currently available. To ensure that the Forest Service can meet its statutory and regulatory responsibilities and is able to inform management of forests and other natural areas to provide Non-Timber Forest Products in a sustainable way, the Forest Service seeks to obtain OMB approval to collect information from people who harvest Non-Timber Forest Products and from people who manage, make policies for or otherwise have a stake in the management of lands where non-timber forest products are harvested or may be harvested.

Relevant Statutes and Regulations

1. The Multiple-Use Sustained-Yield Act of 1960 requires the Forest Service to manage National Forests “under principles of multiple use and to produce a sustained yield of products and services.” ‘‘Sustained yield of the several products and services’’ is defined as “the achievement and maintenance in perpetuity of a high level annual or regular periodic output of the various renewable resources of the national forests without impairment of the productivity of the land.”

2. The Forest and Rangeland Renewable Resources Research Act of 1978 authorizes US Forest Service “investigations, experiments, tests, and other activities… to obtain, analyze, develop, demonstrate, and disseminate scientific information about protecting, managing, and utilizing forest and rangeland renewable resources in rural, suburban, and urban areas.”

This Act and subsequent legislation enshrined in 16 U.S. Code § 1601 requires the Secretary of Agriculture to update a Renewable Resource Assessment every ten years, including a comprehensive inventory of all National Forest System renewable resources. The inventory must be kept current, must identify new and emerging resources and values, must evaluate opportunities for improving their yield of tangible and intangible goods and services, and must analyze potential effects of global climate change on the condition of renewable resources on the forests and rangelands of the United States.

3. Section 219.10 of the 2012 USDA Forest Service Planning Rule specifically requires “consideration of habitat conditions for wildlife, fish, and plants commonly enjoyed and used by the public for hunting, fishing, trapping, gathering, observing, and subsistence” on national forests [italics added]. The 2012 Planning Rule also “emphasizes providing meaningful opportunities for public participation early and throughout the [National Forest management] planning process.”

4. The United States is a signatory to the Montreal Process, an agreement among 12 nations to work towards sustainable use and management of temperate and boreal forests. The Montreal Process requires each nation to report every 5 years on criteria and indicators for sustainable use of temperate and boreal forests, including subsistence use of forest products.
   
   Because of lack of data, the U.S. capacity to fulfill its reporting obligations is severely limited.
   
   
   

5. The Pilot Project on Forest Botanicals (P.L. 106-113, sect. 339(a)) directs the Secretary of Agriculture to establish a program for national forest lands that: (a) establishes fair market value of commercially traded Non-Timber Forest Products, (b) recovers some administrative costs, (c) assures sustainable harvest of Non-Timber Forest Products, and (d) provides for their personal use.

6. The Cooperative Forestry Assistance Act of 1978 [Section (9)(a), Findings] states that “The Congress finds that— (1) the health of forests in urban areas and communities, including cities, their suburbs, and towns, in the United States is on the decline; (2) forest lands, shade trees, and open spaces in urban areas and communities improve the quality of life for residents; … and (7) strengthened research, education, technical assistance, and public information and participation in tree planting and maintenance programs for trees and complementary ground covers for urban and community forests are needed to provide for the protection and expansion of tree cover and open space in urban areas and communities.”

Section (9)(b)(8) states that “The purposes of this section are to—… (8) expand existing research and educational efforts intended to improve understanding of— (A) tree growth and maintenance, tree physiology and morphology, species adaptations, and forest ecology, (B) the value of integrating trees and ground covers, (C) the economic, environmental, social, and psychological benefits of trees and forest cover in urban and community environments.”

Section 9(c) authorizes the Secretary to work with “State foresters or equivalent State officials,” “interested members of the public, including non-profit private organizations,” and “directly with units of local government and others” in carrying out the authorized activities.

Section 9(d) states that “The Secretary, in cooperation with State foresters and State extension directors or equivalent State officials and interested members of the public, including nonprofit private organizations, shall implement a program of education and technical assistance for urban and community forest resources. The program shall be designed to… (4) assist in the development of State and local management plans for trees and associated resources in urban areas and communities; and (5) increase public understanding of the energy conservation, economic, social, environmental, and psychological values of trees and open space in urban and community environments and expand knowledge of the ecological relationships and benefits of trees and related resources in these environments.”

These sections of the Community Forestry Assistance Act specifically authorize the Forest Service to conduct research and give advice on the management of urban forests that are outside of the National Forest system.

7. National Environmental Policy Act of 1969 (PL 91-190), Section 102(2)(A) directs federal agencies to "utilize a systematic, interdisciplinary approach which will ensure the integrated use of the natural and social sciences...in decision making which may have an impact on man's environment."

8. The Food, Conservation, and Energy Act (2008, Public Law 110-234) Cultural and Heritage Cooperation Authority, SEC. 8105. Forest Products for Traditional and Cultural Purposes: “(a) In General- Notwithstanding section 14 of the National Forest Management Act of 1976 (16 U.S.C. 472a), the Secretary may provide free of charge to Indian tribes any trees, portions of trees, or forest products from National Forest System land for traditional and cultural purposes.”

9. The American Indian Agricultural Resources Management Act (1993), Sec. 105 (a) (4)) has implications on tribal uses of non-timber forest and related agricultural products and US government Trust responsibilities. "Agricultural product" includes crops, livestock, forage and feed, grains, and any other marketable or traditionally used materials, which would be applicable to some Non-Timber Forest Products.

10. The National Indian Forest Resources Management Act (1990), Sec. 303 addresses “forest product marketing assistance, including evaluation of marketing and development opportunities related to Indian forest products and consultation and advice to tribes, tribal and Indian enterprises on maximization of return on forest products” where ‘forest product' means “…(C) bark, (D) Christmas trees, stays, branches, firewood, berries, mosses, pinyon nuts, roots, acorns, syrups, wild rice, and herbs, (E) other marketable material.”

11. The American Indian Religious Freedom Act (1978) directs the President to instruct Departments and agencies to “evaluate their policies and procedures in consultation with native traditional religious leaders in order to determine appropriate changes necessary to protect and preserve Native American religious cultural rights and practices.” This includes access to and the use of Non-Timber Forest Products for traditional and cultural ritual, ceremonial or other related religious purposes.

12. The Alaska National Interest Lands Conservation Act of 1980 (ANILCA). ANILCA specifies that subsistence is open to “rural residents of Alaska, including both Natives and non-Natives” where subsistence is defined as: “the customary and traditional uses by rural Alaska residents of wild, renewable resources for direct personal or family consumption as food, shelter, fuel, clothing, tools, or transportation; for the making and selling of handicraft articles out of nonedible byproducts of fish and wildlife resources taken for personal or family consumption; for barter, or sharing for personal or family consumption; and for customary trade.” (Section 803). Section 811(a) directs the Secretary of the Interior to ensure that: “Rural residents engaged in subsistence uses will have reasonable access to subsistence resources on the public lands. Federal and State agencies (which includes the U.S. Forest Service) will undertake research on fish, wildlife, and subsistence use on public lands.”

13. EO 13007: Indian Sacred Sites (May 24, 1996): ‘Sacred site’ means “any specific, discrete, narrowly delineated location on Federal land that is identified by an Indian Tribe, or Indian individual determined to be an appropriately authoritative representative of an Indian religion, as sacred by virtue of its established religious significance to, or ceremonial use by, an Indian religion.”
    
    Many tribes harvest Non-Timber Forest Products at sacred sites for specific religious or related spiritual practices for cultural purposes.

14. The Forest Service’s 2010 National Report on Sustainable Forests affirms the agency’s “all-lands” approach to managing the nation’s natural resources, including forests that are not part of the National Forest system. Gathering of Non-Timber Forest Products is addressed many times in this report.

15. The Tribal Forest Protection Act of 2004 has provided opportunities for tribes to treat National Forest lands bordering tribal lands to ensure access to NTFPs through forest restoration. Obtaining data on access to Non-Timber Forest Products could promote fulfillment of that law by identifying other critical restoration needs.

16. Executive Order 12898 - Federal Actions to Address Environmental Justice in Minority Populations and Low-Income Populations. 59 FR 7629; February 16, 1994. The E.O. directs federal agencies to identify and address the disproportionately high and adverse human health or environmental effects of their actions on minority and low-income populations, to the greatest extent practicable and permitted by law. The order also directs each agency to develop a strategy for implementing environmental justice. The order is also intended to promote nondiscrimination in federal programs that affect human health and the environment.

17. The U.S. Forest Service Northern Research Station conducts research that aligns with the Forest Service Strategic Plan, and the Non-Timber Forest Products research has the potential to support all three Forest Service Strategic Goals (sustain our Nation’s forests and grasslands, deliver benefits to the public, and apply knowledge globally). This research also fits directly in the Research Work Unit Description of NRS-09 People and Their Environments.

2. Indicate how, by whom, and for what pur­pose the information is to be used. Except for a new collec­tion, indicate the actual use the agency has made of the infor­ma­tion received from the current collec­tion.

1. What information will be collected - reported or recorded? (If there are pieces of information that are especially burdensome in the collection, a specific explanation should be provided.)

There are two target audiences for this information collection: foragers themselves, and land managers or policy makers who make decisions for lands where foraging may occur.

We have identified a broad set of questions to collect information on actual Non-Timber Forest Products gathering practices across urban to rural areas on both public and private lands. For example, the questions pertain to:

(1) People-Who harvests Non-Timber Forest Products?;

(2) Places-Where are people harvesting Non-Timber Forest Products? What factors affect where people harvest? Who owns the land(s) where Non-Timber Forest Products are being harvested?

(3) Species- What species are harvested? and

(4) Practices- How do people harvest Non-Timber Forest Products? How does harvesting affect the sustainability of Non-Timber Forest Products? How are harvested materials processed, distributed, and consumed?.

Data collection under this ICR will also include information on managing public lands where Non-Timber Forest Products gathering may take place. Questions for land managers or policy makers include, for example:

1. Have you observed people foraging [where you work]? What species were they collecting?

2. Have you spoken with people foraging [where you work]? If so, what was the nature of these encounters? Did you talk about their motivations for foraging?

3. Are there policies or regulations that pertain to foraging [where you work]?

4. Can you imagine any benefits from encouraging people to forage for plant products and mushrooms [where you work]?
   
   
   

Finally, data collections under this ICR will seek to obtain data on attitudes, values, behaviors, beliefs, customs, cultural significance, presumed health benefits, generational participation, seasonality of gathering, supply chain, marketing, and other aspects of non-timber forest products gathering. Established scales and questions that assess environmental attitudes, behaviors and perceptions may therefore be included in a given data collection process. The information gathered by these questions provides a broader context to understand foraging behavior. In turn, this deeper understanding will help improve outreach to different groups and individuals, and help frame policy and communication practices to better meet Forest Service goals and forest users’ needs and provides environmental justice.

2. From whom will the information be collected? If there are different respondent categories (e.g., loan applicant versus a bank versus an appraiser), each should be described along with the type of collection activity that applies.

Information about the topics listed in 2.a. will be collected from people who harvest Non-Timber Forest Products and land managers to understand their experiences and concerns related to Non-Timber Forest Product harvesting. We may also collect data from land owners and managers. These may include federal, state, and local public land managers, American Indian tribes, nonprofit organizations who hold and manage land, and private landowners.

3. What will this information be used for - provide ALL uses?

The Forest Service will collect, analyze, and interpret data gathered through this IC to develop a scientific foundation for information provided to:

• Land managers seeking to comply with legal mandates, develop new policies, and/or design sustainable management practices related to Non-Timber Forest Products;

• Landscape designers interested in creating landscapes that support Non-Timber Forest Products gathering;

• Public health officials interested in the contributions of nature and greenspaces to addressing growing national health costs from diabetes, obesity, and stress-related illnesses;

• Green infrastructure engineers seeking to create multi-functional landscapes that can process stormwater, cool cities, and feed or otherwise provide tangible goods for people;

• Federal officials who need to make periodic reports to satisfy international treaty requirements;

• American Indians and Alaskan Natives in support of preserving and perpetuating traditional ecological knowledge and cultural practices associated with uses of Non-Timber Forest Products; and

• Scientists interested in furthering scholarly work on non-timber forest products gathering.

Findings from this research will be published in the professional and academic literature in order to reach the widest possible audience of stakeholders and interested parties. Data and findings may also be presented to professionals, land managers, non-profit groups with an interest in foraging, or lay audiences and to audiences at academic conferences.

4. How will the information be collected (e.g., forms, non-forms, electronically, face-to-face, over the phone, over the Internet)? Does the respondent have multiple options for providing the information? If so, what are they?

The information will be collected using a variety of methods, including but not limited to:

• Paper, telephone, and electronic surveys;

• In-person or virtual interviews (with individuals or groups);

• Focus groups;

• Participant observation;

• Other appropriate social science methods.
  
  
  

Specific data collection methods will be selected with a target audience in mind. For example, land managers may be reached successfully by a telephone or in-person interview, occasional foragers may be asked to complete an online survey, and foragers from a new immigrant population may need to be interviewed in person with others from their ethnic group. Whenever possible, multiple methods will be used to ease participation for potential respondents. Details will be provided in reports to OMB. Also wherever possible, electronic means of data collection will be used as they are easier for the respondent. However, some respondent populations may require a paper version in order for the survey to be accessible (e.g., technology familiarity, internet divide, etc.).

5. How frequently will the information be collected?

The intent is to collect information on a one-time basis with each participant or group in a given location or community of interest. Multiple projects may run simultaneously in different locations.

6. Will the information be shared with any other organizations inside or outside USDA or the government?

In most cases the data collected under this ICR will be publicly available with the exception noted below. The audiences for non-timber forest products information are natural resource managers, public open space planners and designers, Tribes, policy makers, other decision makers, other environmental professionals, as well as the people who harvest Non-Timber Forest Products themselves.

With respect to American Indian and Alaska Native peoples, we will comply with Chapter 32A Cultural and Heritage Cooperation Authority, Prohibition on Disclosure. The release of information on American Indians and Alaskan Native’s uses of Non-Timber Forest Products is addressed in Title 25, Chapter 32A Cultural and Heritage Cooperation Authority, § 3056. Limited information on non-timber forest products use by tribes will be shared with others and only if desired by the tribes.

7. If this is an ongoing collection, how have the collection requirements changed over time?

This is a new Information Collection.

3. Describe whether, and to what extent, the collection of information involves the use of auto­mat­ed, elec­tronic, mechani­cal, or other techno­log­ical collection techniques or other forms of information technol­o­gy, e.g. permit­ting elec­tronic sub­mission of respons­es, and the basis for the decision for adopting this means of collection. Also describe any con­sideration of using in­fo­r­m­a­t­ion technolo­gy to re­duce bur­den.

When surveys are used, they will be made available online and by request in hard copy. Publicly accessible information gathered from online chat forums and social media sites may be collected without any burden to the participants as one means of reducing burden. In some circumstances, surveys may be administered in person, with the research assistant noting respondent answers on the form. When a respondent has language, physical disability, or related issues this can ease the burden and allow them to more readily provide information if they wish to.

4. Describe efforts to identify duplica­tion. Show specifically why any sim­ilar in­for­mation already avail­able cannot be used or modified for use for the purpos­es de­scri­bed in Item 2 above.

In preparation for the submission of this Information Collection Request package, we thoroughly searched the scientific and professional literature for published information on Non-Timber Forest Product harvesting. The majority of studies to date have been done outside of the United States, especially in developing countries. The only papers that have been published on non-commercial Non-Timber Forest Product harvesting practices in the United States (see next 3 paragraphs below) have been conducted by people who would be involved directly or as advisors in these collection efforts.

A limited amount of research related to Non-Timber Forest Product harvesting has been conducted by researchers within and outside the U.S. Government. Research conducted primarily with European Americans in the city of Seattle has found that Non-Timber Forest Product harvesters are very diverse in terms of their cultural backgrounds, harvesting histories, and harvesting practices. This information has limited applicability to the intended purposes of this ICR. Building on that work, the Information Collections proposed here will include Non-Timber Forest Product harvesting by diverse communities in a broad sample of cities and rural areas across the United States and provide more detailed information about who is gathering what, how, and where.

Other previous research has analyzed Forest Inventory and Analysis (FIA) data collected by the Forest Service to identify the geographic distribution of trees that produce desirable non-timber forest products. This work has also looked at the ecological impacts of gathering and harvesting on non-timber forest product producing tree species and analyzed the economic implications of growing non-timber forest product tree species on private property. But this work has not studied non-timber forest products gathering practices from the non-land owner gatherer, landscape designer, or public land manager point of view. In addition, non-timber forest products are available from many plant species, not just trees.

The Forest Service’s National Woodland Owner Survey (OMB Control No: 0596-0078) asks private forest landowners whether gathering has occurred in the past or is anticipated to occur in the future. The survey is limited and does not ask detailed questions about non-timber forest products gathering practices and the responses pertain only to privately-owned forests. It also does not ask who does this harvesting or why.

Other studies on non-timber forest products have focused on individual species like ramps or morel mushrooms that are desirable for gathering. None of this research examines general gathering practices by individuals or cultural groups.

We also thoroughly searched the OIRA database for similar Information Collections that have been submitted for OMB review by federal agencies. We searched Forest Service, National Park Service, Bureau of Land Management, Fish & Wildlife Service, and Environmental Protection Agency surveys because these agencies have natural resource management or environment-focused missions. We used the search terms “nontimber forest products,” “forage,” “non-timber forest products,” “NTFP,” “wild plants,” “wild fruit,” “wild food,” and “mushroom.”

5. If the collection of information im­pacts small businesses or other small entities, describe any methods used to mini­mize burden.

The proposed Information Collection does not specifically target small businesses. Small not-for-profit community, educational, or cultural organizations may be contacted to raise awareness about the project and to request assistance in recruiting participants in the communities they serve. Participation will be voluntary and individuals will be told that they are free to limit time given to researchers or discontinue participation at any time.

6. Describe the consequence to Federal program or policy activities if the collection is not conducted or is con­ducted less fre­quent­ly, as well as any technical or legal obstacles to reducing burden.

The Forest Service’s mission is to care for the land and serve people. Legislation directs the agency to provide Non-Timber Forest Products for personal and traditional-cultural use on a sustainable basis. Increasingly, the agency also focuses on providing information about forests and greenspaces to the majority of U.S. citizens who live in cities. The agency is also a primary source of trusted information (per the Forest Service Strategic Goal “apply knowledge globally”) and questions about foraging practices are on the rise. Without this information the Forest Service and other land management agencies will not have a scientific basis for managing non-timber forest product resources and the lands that support them, and will not have the necessary information to provide technical advice on this issue to other land management agencies and individuals.

7. Explain any special circumstances that would cause an Information Collection to be con­ducted in a manner:

• Requiring respondents to report informa­tion to the agency more often than quarterly;

• Requiring respondents to prepare a writ­ten response to a collection of infor­ma­tion in fewer than 30 days after receipt of it;

• Although there is no requirement because participation is voluntary, due to the nature of surveys, respondents will typically respond in fewer than 30 days of receipt of the request to participate.

• Requiring respondents to submit more than an original and two copies of any docu­ment;

• Requiring respondents to retain re­cords, other than health, medical, governm­ent contract, grant-in-aid, or tax records for more than three years;

• In connection with a statisti­cal sur­vey, that is not de­signed to produce valid and reli­able results that can be general­ized to the uni­verse of study;

• Requiring the use of a statis­tical data classi­fication that has not been re­vie­wed and approved by OMB;

• That includes a pledge of confidentiality that is not supported by au­thority estab­lished in statute or regu­la­tion, that is not sup­ported by dis­closure and data security policies that are consistent with the pledge, or which unneces­sarily impedes shar­ing of data with other agencies for com­patible confiden­tial use; or

• Requiring respondents to submit propri­etary trade secret, or other confidential information unless the agency can demon­strate that it has instituted procedures to protect the information's confidentiality to the extent permit­ted by law.

There are no other special circumstances. The collection of information is conducted in a manner consistent with the guidelines in 5 CFR 1320.6.

8. If applicable, provide a copy and iden­tify the date and page number of publication in the Federal Register of the agency's notice, required by 5 CFR 1320.8 (d), soliciting com­ments on the Information Collection prior to submission to OMB. Summarize public com­ments received in response to that notice and describe actions taken by the agency in response to these comments. Specifically address com­ments received on cost and hour burden.

The 60-day notice soliciting comments was published in the Federal Register on June 17, 2016, Vol. 81, No. 117, Pages 39624 -39626.

Document Number: 2016-14316

Shorter URL: https://federalregister.gov/a/2016-14316

The Forest Service received one comment from the general public describing their desire to enhance protection of National Forests. The Forest Service proceeded to thank the individual for their comment and took the comment into consideration.

Describe efforts to consult with persons out­side the agency to obtain their views on the availability of data, frequency of collection, the clarity of instructions and record keeping, disclosure, or reporting format (if any), and on the data elements to be recorded, disclosed, or reported.

The following individuals outside the Forest Service have been consulted about the need for Non-Timber Forest Products data in their area of expertise and the data elements to be recorded, disclosed, or reported.

Miriam Avins, Founder & Executive Director, Baltimore Green Space, -- Consulted on the need and value of Non-Timber Forest Products information for efforts to conserve and enhance the values of greenspaces in Baltimore.

Keeve Nachman, Center for a Livable Future, Johns Hopkins Bloomberg School of Public Health -- Consulted about information needed to model risk of exposure to contaminants for Non-Timber Forest Products harvested in urban environments.

Patrick Hurley, Chair, Department of Environmental Studies, Ursinus College -- Consulted on information needed to understand the environmental and social factors that influence where people harvest Non-Timber Forest Products.

Rebecca McLain, Portland State University -- Consulted on methods for collecting, recording, analyzing, and reporting Non-Timber Forest Product information.

Melissa Poe, National Oceanic and Atmospheric Administration -- Consulted on methods for collecting, recording, analyzing, and reporting Non-Timber Forest Product information.

Matthew Potteiger, Professor, Landscape Architecture, State University of New York, College of Environmental Science and Forestry -- Consulted on information needed to plan and design foodscapes.

Jackie Lu, Natural Resources Group, New York City Department of Parks and Recreation -- Consulted on needs, interests, and concerns of a major city greenspace management organization relative to Non-Timber Forest Product harvesting in city parks.

Consultation with representatives of those from whom information is to be obtained or those who must compile records should occur at least once every 3 years even if the col­lection of information activity is the same as in prior periods. There may be circumstances that may preclude consultation in a specific situation. These circumstances should be explained.

This is a new collection, and as such, there are no persons with whom to consult.

We will confer with key informants in each location prior to conducting information collections for suggestions on simplifying the data collection process in their community.

We will adhere to legal requirements of EO 13175: Consultation and Coordination with Indian Tribal Governments where appropriate.

9. Explain any decision to provide any payment or gift to respondents, other than re-enumeration of contractors or grantees.

A modest non-monetary incentive (such as local museum passes or a book) may be offered to members of the public who participate in interviews or focus groups. Such tokens will be nominal in value, and will be used to increase participation and to signify mutual respect between the researchers and participants.

10. Describe any assurance of confidentiality provided to respondents and the basis for the assurance in statute, regulation, or agency policy.

Confidentiality and/or anonymity of participants and places will be assured by keeping any personal identifying information separate from information about Non-Timber Forest Product harvesting provided in interviews, focus groups, surveys, or observation. The exception will be instances in which individuals explicitly request to have their names associated with the information they provide (this is sometimes requested by research participants).

In compliance with EO 13175, Consultation and Coordination with Indian Tribal Governments, tribes may wish to voluntarily disclose and share information regarding their uses of Non-Timber Forest Products for traditional and cultural purposes. Prohibition on disclosure, if desired by tribal government or the federal government, regarding the release of information on American Indians and Alaskan Native’s uses of non-timber forest products is addressed in Title 25, Chapter 32A Cultural and Heritage Cooperation Authority, § 3056.

In case of FOIA requests for specific information, we will disclose what is required by law. Personal or financial information would be kept confidential under FOIA exemptions 4 (“information that concerns business trade secrets or other confidential commercial or financial information”) and 6 (“information that, if disclosed, would invade another individual's personal privacy”).

11. Provide additional justification for any questions of a sensitive nature, such as sexual behavior or attitudes, religious beliefs, and other matters that are commonly considered private. This justification should include the reasons why the agency considers the questions necessary, the specific uses to be made of the information, the explanation to be given to persons from whom the information is requested, and any steps to be taken to obtain their consent.

Study participants will be clearly told that they need not answer any questions on subjects they consider sensitive.

Any information from American Indians and Alaskan Natives will adhere to EO 13175 and American Indian Religious Freedom Act (AIRFA), 16 U.S.C. 1996.

12. Provide estimates of the hour burden of the collection of information. Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated.

• Indicate the number of respondents, frequency of response, annual hour burden, and an explanation of how the burden was estimated. If this request for approval covers more than one form, provide separate hour burden estimates for each form.

a) Description of the collection activity

b) Corresponding form number (if applicable)

c) Number of respondents

d) Number of responses annually per respondent,

e) Total annual responses (columns c x d)

f) Estimated hours per response

g) Total annual burden hours (columns e x f)

Following is an informed reasonable estimate of the total number of participants over the next three years.

A variety of instruments and platforms will be used to collect information from respondents. We anticipate that over a three-year period, there will be no more than 14,250 respondents. Given these estimates, the total burden hours over the three year will not exceed 5,613 burden hours (see table 1 below).

Typically, each person is expected to participate by interview, focus group, or survey one time with no follow-up unless requested by the individual. In certain circumstances where a longitudinal or pre/post study is warranted, some participants may volunteer to provide information more than once. The number of participants in each location will depend on the size and diversity of the general population in that location, as well as the number of foragers in the area.

For the purposes of estimating and budgeting for the overall 3 year burden for this Generic Clearance, we have made the basic assumptions outlined in table 1 below. Each Information Collection request submitted under this Generic Clearance will provide the specific estimates of burden related to that particular Information Collection request, along with an explanation of how those estimates were determined.

We estimate the total dollar value of the burden hours for this collection (over a three-year period) to be $132,242. We arrived at this figure by multiplying the estimated burden hours over a three-year period by $23.56, the wage rate (including benefits) based on the Independent Sector national valuation of volunteer time for 2015. https://www.independentsector.org/volunteer_time. We used this rate because this research is expected to draw people from a wide range of employments, cultural backgrounds, ages, locations, and life circumstances.

Table 1

Type of Collection	Annual No. of Respondents	3 Yr. Total No. of Respondents	Completion Time	Annual Burden Hours	3 Yr. Total Burden Hours
Surveys Assume 12 surveys/year X 3 years = 36 surveys total Assume 250 responses for each survey effort Assume 100 non-respondents per survey effort	3,000 respondents 1,200 non-respondents	9,000 total respondents (3 years X 3,000) 3,600 total non-respondents (3 years X 1200)	25 minutes (.42 hours) 2 minutes (.03 hours)	1,260 hrs. for respondents 36 hrs, for non-respondents	3,780 hrs. for respondents 108 hrs. for non-respondents
Focus groups Assume 5 groups/year X 3 years= 15 groups total (Assume 10 respondents per group)	50	150 (15 X 10)	90 minutes per group (1.5 hours)	75	225
Structured Interviews Assume 10 interview projects/year x 3 years= 30 interview projects total (assume 50 respondents per interview effort)	500	1,500 (30 x 50)	60 minutes (1 hour)	500	1,500
Total	4,750	14,250	-	1,871	5,613

Record keeping burden should be addressed separately and should include columns for:

a) Description of record keeping activity:

b) Number of record keepers:

c) Annual hours per record keeper:

d) Total annual record keeping hours (columns b x c):

There are no record-keeping requirements placed upon the respondents.

Provide estimates of annualized cost to respondents for the hour burdens for collections of information, identifying and using appropriate wage rate categories.

See above

13. Provide estimates of the total annual cost burden to respondents or record keepers resulting from the collection of information, (do not include the cost of any hour burden shown in items 12 and 14). The cost estimates should be split into two components: (a) a total capital and start-up cost component annualized over its expected useful life; and (b) a total operation and maintenance and purchase of services component.

There are no capital operation and maintenance costs.

14. Provide estimates of annualized cost to the Federal government. Provide a description of the method used to estimate cost and any other expense that would not have been incurred without this collection of information.

The response to this question covers the actual costs the agency will incur as a result of implementing the Information Collection. The estimate should cover the entire life cycle of the collection and include costs, if applicable, for:

• Employee labor and materials for developing, printing, storing forms

• Employee labor and materials for developing computer systems, screens, or reports to support the collection

• Employee travel costs

• Cost of contractor services or other reimbursements to individuals or organizations assisting in the collection of information

• Employee labor and materials for collecting the information

• Employee labor and materials for analyzing, evaluating, summarizing, and/or reporting on the collected information

Because the location of specific Information Collections is unknown, the following estimates are made based on the Denver, Colorado federal employee pay schedule (Denver’s 2016 locality pay at 22.93% is in the middle of the pack for mid- to large-size U.S. cities). While the interviews for each survey location are expected to be conducted in about a year, there is pre-work to do beforehand and data analysis afterward so a two-year project timeline is expected.

Table 3

ACTION ITEM	PERSONNEL	GS LEVEL	ANNUAL SALARY	ANNUAL TOTAL	3 YEAR TOTAL
Project oversight and coordination, data analysis	Project PI	13, step 3 @25% of time	$96,832	$24,208	$72,624
Outreach to recruit respondents, conducting interviews, data management and analysis	Project technicians (4)	9, step 3 @50% of time	$56,151	$112,302	$ 336,906
Purchase of data analysis software (SPSS, NVivo)*				$4,740*	$4,740
				$141,250	$414,270

*In many cases, federal employees or non-federal collaborators on the project will already have the necessary software. SPSS (the basic statistics package) is about $2500; NVivo 11 is about $1670 and NVivo upgrades are $570 (as of September 2016).

15. Explain the reasons for any program changes or adjustments reported in items 13 or 14 of OMB form 83-I.

This is a new Information Collection.

16. For collections of information whose results are planned to be published, outline plans for tabulation and publication.

In general, summarized, descriptive, comparative (e.g. ANOVA [Analysis of Variance]), or modeling (e.g., Structural Equation Modeling) statistics of collected information may be shared in presentations or published in peer-reviewed journal articles, other publications, or on websites that are practitioner-oriented (specific analytic methods to be used in any given survey will be described in the review package submitted to OIRA prior to data collection). Possible professional journals include those that focus on natural resource management, natural resource policy, and open space design such as Urban Forestry and Urban Greening, Ecology and Society, Society and Natural Resources, Landscape and Urban Planning, Forest Science, Journal of Forestry, Small Scale Forestry, and Human Ecology Review. Analysis and tabulation of data will follow established social science protocols. Practitioner-oriented media include The National Recreation and Parks Association magazine and the Journal of the American Planning Association, web pages, and plain language research summaries targeted to land managers and policy makers.

Any information on non-timber forest products use by tribes, if applicable, may have particular aspects or specific details removed prior to publication or public release in compliance with Chapter 32A Cultural and Heritage Cooperation Authority, Prohibition on Disclosure. The release of information on American Indians and Alaskan Native’s uses of non-timber forest products is addressed in Title 25, Chapter 32A Cultural and Heritage Cooperation Authority, § 3056.

17. If seeking approval to not display the expiration date for OMB approval of the Information Collection, explain the reasons that display would be inappropriate.

The valid OMB control number and expiration date will be displayed on all Information Collection instruments.

18. Explain each exception to the certification statement, "Certification Requirement for Paperwork Reduction Act."

The agency is able to certify compliance with 5 CFR 1320.

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